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Business entities must arrive with their ownership structure resolved to natural persons. This page covers who must be reported, at what threshold, and how to handle ownership through intermediate companies.

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Requirements

Lead requires Beneficial Ownership information in line with the CIP program reviewed during Due Diligence. At a minimum, this should include all Beneficial Owners (UBOs) who are natural persons with direct or indirect ownership of 25% or greater.
  • Control Person: you must also identify one natural person with significant responsibility to control, manage, or direct the business (e.g., CEO, COO, President), required regardless of ownership percentage.
  • Thresholds: if your KYB process expressly states a lower percentage than 25%, all beneficial owners meeting your stated percentage must be provided.

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The “Drill-Down” Rule

A beneficial owner must be a natural person. If a business entity (a parent or holding company) owns 25% or more of the customer, you cannot list that entity as the owner. Instead, apply the same ownership requirement to that entity’s owners. Continue up the chain until you have identified all natural persons with a 25%-or-greater indirect stake in the original customer.
  • Customer: Bob’s Pizza Company
  • Owners: Alan (individual, 60%) · Bob (individual, 40%, also CEO)
  • Other individual: Charlie (an authorized signer on the account)
  • Action:
    1. Create individual profiles for Alan, Bob, and Charlie with authorized-signer data.
    2. Create the business profile for Bob’s Pizza Company.
    3. Link Alan as a beneficial owner (owns >25%).
    4. Link Bob as a beneficial owner (owns >25%) AND as the control person (CEO).
    5. Charlie does not need to be linked as an owner or control person.
  • Customer: SaaS Co · Immediate owners: Parent Corp (entity, 80%) · Jane Smith (individual, 20%)
  • Drill down into Parent Corp (an entity owning >25%). Parent Corp’s owners: Holding LLC (entity, 50%) · Mark Lee (individual, 50%)
  • Drill down again into Holding LLC. Holding LLC’s owner: Susan Kay (individual, 100%)
  • Final UBO calculation for SaaS Co:
    • Jane Smith: 20% direct → not a 25% UBO
    • Mark Lee: 50% of 80% = 40% indirect → is a 25% UBO
    • Susan Kay: 100% of 50% of 80% = 40% indirect → is a 25% UBO
  • Conclusion: provide profiles for Mark Lee and Susan Kay as beneficial owners (authorized-signer data requirements); do not report Parent Corp or Holding LLC as owners; also identify and provide the profile for SaaS Co’s control person (e.g., its CEO), who may or may not be one of these individuals.